Recent comment letters in response to the OCC's fintech charter show increased criticism for the agency's proposal; consumer protection groups, community banks and state regulators have all voiced opposition while supporters have been disappointed by the process for the charter; supporters are concerned that financial inclusion plans and other provisions for the charter might be overly burdensome; consumer protection provisions are also a point of emphasis with groups suggesting specific consumer protection measures such as interest rate caps, default rate limitations and underwriting standards; lack of details on a number of business factors including capital requirements and balance sheet versus off balance sheet funding have also reduced confidence in the charter. Source

States have voiced their opposition against the OCC's fintech charter proposal and could be a factor limiting the charter from proceeding; with the charter, fintechs can be granted special purpose national bank status which includes national governance with exemption from state laws; many states have actively integrated regulations and processes for alternative lenders, including state usury laws and regulations for payday lenders; opposing states say the charter would complicate existing state level laws and initiatives. Source